Turnedaway.ca is licensed under Mortgage Brokers Network Inc., FSRA #13257. We respect the privacy of our clients and we are committed to keeping personal information accurate, confidential, secure, and private. We have adopted the following Privacy Policies to ensure that we continue to meet our commitment to you, our client.

“Personal Information” refers to all information affiliated with any applicant who approaches Mortgage Brokers Network. This may include, but is not limited to: an individual’s name, home address, age, income, credit history, financial information, personal preferences or any information about their family.

Our Privacy Policy has been designed around Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), which includes the Ten Privacy Principles outlined in the Canadian Standards Association Model Code for the Protection of Personal Privacy. The principles we will adhere to are as follows:

Principle 1 – Accountability: All employees who handle sensitive information will be accountable for any personal information in their possession or custody, including any information disclosed to third parties for purposes of providing services requested by clientele.

Principle 2 – Identifying Purposes: Agents/brokers will inform clients of the purposes for which any personal information is collected.  This will be done before or at the time the information is requested.

Principle 3 – Consent: Agents/brokers will obtain consent before or when personal information is collected, used, or disclosed. Clients may withdraw their consent at any time.

Principle 4 – Limiting Collection: The information collected by agents/brokers will be limited to those details necessary for the purposes it has identified to a client to perform the services requested. Any information will be collected by fair and lawful means.

Principle 5 – Limiting Use, Disclosure and Retention: Personal information will only be used or disclosed for the purpose for which it was collected, unless the client has consented otherwise. Personal information will only be retained for the amount of time needed to fulfill the purpose for which it was collected. Retained information will follow the mandated timelines in accordance with FSRA guidelines.

We will implement a retention schedule to ensure prompt destruction and erasing procedures. Once the retention period is over, the brokerage will securely destroy & erase any personal information that is no longer required by law.  All destruction of personal information will be overseen by the designated compliance officer/principal broker.

Principle 6 – Accuracy: Agents/brokers will keep personal information as accurate, complete, and current as necessary to fulfill the identified purposes for which it was collected. Clients will have the right to amend information where it is found to be inaccurate or incomplete.

Principle 7 – Safeguarding Personal Information: Personal information will be safeguarded using measures appropriate to the sensitivity of the information being held and in keeping with accepted industry standards.

These will include:

    • physical measures (e.g., locked filing cabinets, restricting access to offices, and alarm systems);
    • up-to-date technological tools (e.g., passwords, encryption, firewalls and security patches);
    • organizational controls (e.g., security clearances, limiting access, staff training and agreements).

The following factors will be reviewed when selecting the right safeguard:

    • the sensitivity of the information and the risk of harm to the individual. For instance, health and financial information would be considered highly sensitive;
    • the amount of information;
    • the extent of distribution;
    • the format of the information (e.g., electronic or paper);
    • the type of storage; and
    • the types and levels of potential risk our organization faces.

We will review security safeguards regularly to ensure they are up to date, and endeavour where possible to address vulnerabilities through regular security audits and/or testing.

We will continually raise awareness with employees to make them mindful of the importance of maintaining the security and confidentiality of personal information, and hold regular staff training on security safeguards

All our employees who have access to personal information will be monitored to ensure they are adhering to our privacy policy and related procedures. To this end, we will have a designated compliance & privacy officer to monitor employee behaviour. To further guarantee the protection of client’s privacy our employees will undergo a criminal background check.

Principle 8 – Openness: Agents/brokers will comply with guidelines to obtain meaningful consent and make information available to its clients, employees and mortgage brokers about the policies and procedures used to manage personal information.  We will ensure that information is in easy to understand terms.

Principle 9 – Access: Upon written request, clients will be informed of the existence, use and disclosure of their personal information, and will be given access to it. Agents/brokers will respond to such requests in a timely manner.

Principle 10 – Challenging Compliance: The brokerage will respond to all complaints in writing as laid out in the FSRA guidelines & policies.  We will advise complainants about the avenues of recourse.  We will record the date of the complaint, it’s nature and direct them to the compliance officer or principal broker.  We will notify the complainant of the outcome promptly and let them know what actions have been taken.  Lastly, we will endeavour to rectify any concerns as quickly as possible.

Summation

Mortgage Brokers Network Inc. has extensive controls in place to maintain the security of its information and information systems. Client and independent broker files will be stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) will be placed on our computer systems and data processing procedures. Physical access to areas where personal information is gathered, processed, or stored will be limited to authorized persons.

We treat our client’s privacy with the utmost importance and will continue to monitor, evaluate and improve our privacy policy on an ongoing basis.  These processes will be governed by the compliance officer/ principal broker.